2. GDS_0310723_v1 1 Ethics & Compliance Training: Are We Having Fun Yet? Mark P. Graves, J.D. Assistant Ethics & Compliance Officer TAP Pharmaceutical Products Inc. Mark P. Graves, J.D. Assistant Ethics & Compliance Officer TAP Pharmaceutical Products Inc.

3. GDS_0310723_v1 2 Guiding Philosophy “The great aim of education is not knowledge but action.” - Herbert Spencer

4. GDS_0310723_v1 3 Overview Putting Theory Into Practice: Communicating with the MTV Generation and Making Compliance Training Interesting, Fun and Effective Know Your Audience Have the Right Resources/Team Use Effective Marketing to “Brand” YOUR Product Use Relevant Case Studies Use Multiple Media to Communicate/Train Dare to Laugh and Poke Fun at Yourself Create Positive Incentives

5. GDS_0310723_v1 4 Making Compliance Training Fun & Effective Know Your Audience Industry Sector Internal External

6. GDS_0310723_v1 5 Making Compliance Training Fun & Effective Know Your Audience Industry Sector Pharma -- Sales & Marketing -- Corporate Office (R&D, Finance, QA, HR, Legal, MIS, etc.) Hospitals, Health Systems, Physician Practices, Managed Care Organizations, etc.

7. GDS_0310723_v1 6 Making Compliance Training Fun & Effective Know Your Audience Internal Board Executive Management Functional Areas – Senior Management – Mid-Level Management Employees Stakeholders

8. GDS_0310723_v1 7 Making Compliance Training Fun & Effective Know Your Audience External Government HHS – OIG – FDA DOJ Congress Media Public

9. GDS_0310723_v1 8 Making Compliance Training Fun & Effective Have the Right Resources/Team Resources Senior Management Support Time Money Technology/Systems People People – Complement your skill sets Emphasize communication skills Emphasize credibility Seek diversity

10. GDS_0310723_v1 9 Making Compliance Training Fun & Effective Use Effective Marketing Techniques to Brand YOUR Product Create a theme, recognizable brand, logo Use visual and vocal branding through color, sound Pay attention to details Font type, size and color Use of punctuation Apply your brand to all of your materials Code of Conduct Training materials PowerPoint presentations Displays and posters Speaking opportunities

11. GDS_0310723_v1 10 Making Compliance Training Fun & Effective Use Relevant Case Studies Tailor training to real-world issues that your audience experiences Makes it real, more memorable and more effective Use role plays or some form of interactive participation Video vignettes Case study teams in live training Interactive computer questions Inject humor when possible but strike careful balance not to go “over the top”

12. GDS_0310723_v1 11 Making Compliance Training Fun & Effective Use Multiple Media to Communicate/Train Redundancy of message can be good Resources allowing, use Live training Computer-based training Voice-mail E-mail Written materials Web-based materials Audio & video tapes Do NOT rely on any ONE medium. Seek to complement and enhance different forms of training.

13. GDS_0310723_v1 12 Making Compliance Training Fun & Effective Dare to Laugh and Poke Fun at Yourself Be yourself Self-deprecating humor works Use seriousness and perceived negativity of subject to lighten tension. Recognize up front that this stuff can be dry and boring Openly express intent NOT to demonize or play “Gotcha!” Focus on service-oriented approach, partnership Openly seek to have fun and laugh at yourselves Don’t overdo it; strike a balance

14. GDS_0310723_v1 13 Making Compliance Training Fun & Effective Create Positive Incentives Add ethics & compliance performance criteria to performance evaluations where achieving goals lead to financial rewards Create team contests involving functional areas, divisions etc. where “winners” will be rewarded

15. GDS_0310723_v1 14 Multiple Dimensions of Compliance Effectiveness Macro – Organizational Impact Legal Operational Micro – Programmatic Impact Structural Substantive Effort/Input Outcomes/Results

16. GDS_0310723_v1 15 HCCA Resource Document “Evaluating and Improving a Compliance Program: A Resource For Health Care Board Members, Health Care Executives and Compliance Officers” Available on home page of HCCA website: www. hcca-info.org

17. GDS_0310723_v1 16 Positive Communications Define Ethics & Compliance Positively as “a way of doing business that adds value.” Ethics & Compliance = Precision + Accuracy =  Better Information/Documentation  Better Decision-Making  Higher Quality/More Efficient Operations  More Competitive Position  Lower Risk of Violations

18. GDS_0310723_v1 17 Positive Communications Counters Negative Perceptions that Ethics & Compliance = Added Costs Administrative Burdens Imposed Rules and Regulations Negative Impact on Business “A pain in the …”

19. GDS_0310723_v1 18 What’s Ahead? Empirical Measurement Using Technology Accountability More, more, more…. Compliance Effectiveness

20. GDS_0310723_v1 19 What’s Ahead? A Theme of Partnership and Common Purpose Between Public & Private Sectors

21. GDS_0310723_v1 20 Food For Thought “With regard to excellence, it is not enough to know, but we must try to have and use it.” Aristotle, Nichomachean Ethics, circa 340 B.C.

22. GDS_0310723_v1 21 Guiding Philosophy “The great aim of education is not knowledge but action.” - Herbert Spencer

23. GDS_0310723_v1 22 Final Thoughts Good compliance is good business!

24. GDS_0310723_v1 23

25. GDS_0310723_v1 24 Contact Information Mark P. Graves Assistant Ethics & Compliance Officer TAP Pharmaceutical Products Inc. 675 North Field Drive Lake Forest, IL 60045 Tel. (847) 582-6529 Fax. (847) 582-5002 e-mail: mark.graves@tap.com

26. GDS_0310723_v1 25 Thank You!